1. Objective

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The objective of this ESG Policy is to establish a clear and transparent framework for the integration of Environmental, Social, and Governance (ESG) considerations into Enerdealers’ business strategy, energy and other commodities trading activities, operational decision-making, and risk management processes.

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This policy supports long-term value creation, responsible energy and other commodities trading practices, effective management of ESG-related operational, supply-chain, regulatory, and reputational risks, and alignment with applicable regulatory and market expectations, including the EU Taxonomy Regulation, the Corporate Sustainability Reporting Directive (CSRD), and climate-related disclosure recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).

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2. Scope

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This policy applies to Enerdealers and all its activities across the energy and other commodities trading lifecycle, including:

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• Commodity sourcing and procurement

• Counterparty, supplier, and producer due diligence

• Trading, logistics, transportation, storage, and delivery

• Risk management, compliance, and sanctions screening

• Contractual arrangements with counterparties and service providers

• Ongoing monitoring and reporting

 

It applies to all employees, management, and governing bodies involved in energy and other commodities trading, operations, risk management, compliance, and governance, and sets expectations for suppliers, logistics providers, and trading counterparties where relevant.

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3. ESG Framework and Principles

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Enerdealers integrates ESG considerations in line with internationally recognized standards and best practices applicable to energy and other commodities trading and global supply chains, including the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights (UNGPs), and relevant European sustainability regulations.

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The Company’s ESG approach is based on the following principles:

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• Integration: ESG factors are systematically integrated into trading decisions, counterparty selection, operational processes, and risk management frameworks.

• Responsible sourcing: Promote responsible sourcing of energy and other commodities, considering environmental and social impacts.

• Transparency and disclosure: Seek appropriate ESG information from suppliers and counterparties.

• Risk-based approach: ESG risks are assessed proportionately, based on commodity type, origin, logistics, and counterparty profile.

• Engagement and improvement: Encourage counterparties to enhance ESG practices over time.

• Reporting: ESG performance and progress are reported in alignment with CSRD, EU Taxonomy, and TCFD, as applicable.

 

4. ESG Integration, Risk Management, and Regulatory Alignment

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Enerdealers identifies, assesses, and manages ESG risks throughout its energy and other commodities trading and operational activities:

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• ESG screening of suppliers, counterparties, producers, and logistics providers

• ESG due diligence proportional to commodity type, origin, geography, and transaction risk

• Identification and mitigation of material environmental, social, and governance risks

• Ongoing monitoring of ESG performance and compliance

• Climate-related risks and opportunities (physical and transition) are assessed in line with TCFD principles

• Alignment with EU Taxonomy where applicable for relevant economic activities

 

5. Governance Structure

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• Board / Senior Management: Strategic oversight, ESG Policy approval, regulatory alignment

• Management, Trading, and Operations Teams: ESG integration in trading and operations

• Risk and Compliance Function: Oversight of ESG risks, sanctions, and compliance

• ESG Function / Designated ESG Responsible: Coordination of ESG implementation, monitoring, reporting, regulatory alignment, and continuous improvement

 

6. Roles and Responsibilities

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• Senior Management: Ensure ESG integration in strategy, trading policies, and risk management

• Trading, Operations, Risk, and Compliance Teams: Identify, assess, and manage ESG risks in commodities, suppliers, logistics, and counterparties

• Suppliers, Counterparties, and Service Providers: Comply with applicable laws, contractual ESG requirements, and cooperate with Enerdealers’ ESG initiatives

 

7. ESG Objectives

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Enerdealers’ ESG objectives are embedded in all aspects of energy and other commodities trading operations, ensuring practical and proportional integration of ESG principles.

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Environmental Objectives

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• Comply with environmental laws and regulations relevant to trading and logistics.

• Integrate environmental risk assessments in supplier and counterparty selection.

• Encourage biodiversity protection and responsible land use among counterparties.

• Consider climate-related risks and opportunities in line with TCFD reccomendations.

 

Social Objectives

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• Promote occupational health and safety within Enerdealers and across suppliers/logistics.

• Support communities indirectly impacted by operations, enhancing transparency.

• Offer employee wellness programs, training, and recognition for ESG contributions.

• Encourage responsible practices in supplier and counterparty networks.

 

Governance Objectives

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• Maintain strong governance for ESG oversight in trading and operations.

• Embed ESG risk management in trading, procurement, and contracts.

• Uphold high ethical standards, including human rights and anti-corruption practices.

• Conduct proportionate ESG due diligence for counterparties, aligned with trade finance and KYC expectations.

 

Diversity and Inclusion Objectives

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• Promote diversity and inclusion at all levels of the organization.

• Implement strategies to recruit, retain, and develop diverse talent.

• Foster an environment of respect, value, and inclusion.

 

Innovation and Collaboration

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• Engage in industry forums, partnerships, and research collaborations.

• Encourage innovative approaches that improve ESG performance in energy and commodities trading.

 

8. ESG Performance Measurement and Reporting

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• Monitor ESG performance through qualitative and quantitative KPIs, including counterparty ESG checklist.

• Transparent reporting aligned with CSRD, EU Taxonomy, and TCFD.

• Documented evidence available for auditors, regulators, banks, and trade finance partners.

 

9. Continuous Improvement and Review

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• ESG Policy reviewed periodically to reflect regulatory developments, best practices, and operational learnings.

• Counterparty ESG due diligence and KPIs updated as required to enhance transparency and risk management.

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